Mitchum v. Foster

Supreme Court of the United States · 1972 · Federal Courts

Federal CourtsAnti-Injunction ActSection 198328 U.S.C. § 228342 U.S.C. § 1983expressly authorized exceptionstate court injunctionsfederal equity

Facts

A Florida prosecuting attorney brought a state-court proceeding to close Mitchum's bookstore as a public nuisance under claimed Florida-law authority, and the state court entered a preliminary order barring continued operation. After further inconclusive state proceedings, Mitchum sued in federal district court alleging that state judicial and law-enforcement officials were depriving him of First and Fourteenth Amendment rights. Relying on 42 U.S.C. § 1983, he sought injunctive and declaratory relief against the state proceeding, claiming Florida law was being unconstitutionally applied and causing great and irreparable harm. The federal district court refused to enjoin the state proceeding because it concluded § 1983 was not within any exception to the Anti-Injunction Act.

Issue

Whether 42 U.S.C. § 1983 is an Act of Congress within the Anti-Injunction Act's "expressly authorized" exception, so that a federal court in a § 1983 suit may enjoin a pending state-court proceeding. More specifically, the question was whether § 1983 permits federal equitable intervention notwithstanding 28 U.S.C. § 2283.

Rule

An Act of Congress falls within the Anti-Injunction Act's "expressly authorized" exception when it creates a specific and uniquely federal right or remedy, enforceable in a federal court of equity, that could be frustrated if the federal court lacked power to stay a state-court proceeding. The statute need not expressly refer to § 2283 or expressly mention injunctions against state-court proceedings. Under that standard, 42 U.S.C. § 1983 is an expressly authorized exception to § 2283.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Phoenix, Maria Ortega operates a neighborhood theater. After Arizona officials file a state-court action to shut it down under a local ordinance, Maria sues those officials in federal court under 42 U.S.C. § 1983, alleging they are using state judicial process to violate her federal constitutional rights and seeking an injunction against the pending state case.

The federal district judge concludes that 28 U.S.C. § 2283 absolutely strips federal courts of power to enjoin any pending state proceeding in a § 1983 suit. Which is the best assessment?

Explanation. The majority held that § 1983 is an Act of Congress within the Anti-Injunction Act's "expressly authorized" exception. Thus, a district court errs if it treats § 2283 as an absolute jurisdictional bar to injunctive relief in every § 1983 suit aimed at a pending state proceeding. The Court did not say an injunction must issue, only that § 2283 does not categorically eliminate federal power.